irrebuttable presumption (Minnesota) · Go Syfert
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irrebuttable presumption in Minnesota

14 Minnesota opinions name it 2 courts 1903–2013 0 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (3)

CaseFollowedCited
State v. Clausengreen
minn · 1992 · cited in 2 Minnesota opinions naming this issue, 2004–2008
2 sentences

2008In State v. Clausen, the supreme court held that the regulation of drug possession — without proof of intent to sell — does not deny defendants due process by creating an irrebuttable presumption of intent to sell. 493 N.W.2d 113, 118 (Minn.1992).

2004Relators argue that the statute violates due process because it creates an irrebuttable presumption of an IPHT from the mere “potential to immediately and adversely threaten public health or safety.” Relators also argue that the statute authorizes an ISTS inspector to “declare a public nuisance that which in fact is not a public nuisance,” and upon such a declaration, “even the County Board cannot undo such a finding.” Relators contend that because the legislature does not have the power to declare what shall be conclusive evidence, this irrebuttable presumption “violates a person’s due proces

22
Welle v. Prozinskigreen
minn · 1977 · cited in 1 Minnesota opinions naming this issue, 1988–1988
1 sentence

1988Welle v. Prozinski, 258 N.W.2d 912, 916 (Minn.1977).

11
Shreve v. Department of Economic Securitygreen
minn · 1979 · cited in 1 Minnesota opinions naming this issue, 1983–1983
1 sentence

1983This is an irrebuttable presumption, Shreve v. Department of Economic Security, 283 N.W.2d 506, 508 (Minn.1979), with an exception granted to a student in training “with the approval of the Commissioner.” Minn. Stat. Sec. 268.08(1)(3) (1982).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
Sandstrom v. Montana green
scotus · 1979
2 sentences

1984Moreover, in the recent Minnesota case of State v. Williams, 324 N.W.2d 154 (Minn. 1982), a lack of qualifying instructions to the effect that the jury could consider the explanation or that it could disregard the presumption was important to the finding that the instruction given was “tantamount to an irrebuttable presumption that denies due process.” Id. at 160 citing Sandstrom v. Montana, 442 U.S. 510 , 99 S.Ct. 2450 , 61 L.Ed.2d 39 (1979).

1984Moreover, in the recent Minnesota case of State v. Williams, 324 N.W.2d 154 (Minn. 1982), a lack of qualifying instructions to the effect that the jury could consider the explanation or that it could disregard the presumption was important to the finding that the instruction given was “tantamount to an irrebuttable presumption that denies due process.” Id. at 160 citing Sandstrom v. Montana, 442 U.S. 510 , 99 S.Ct. 2450 , 61 L.Ed.2d 39 (1979).

21982–1984
Twin City Candy and Tobacco Co. v. A. Weisman Co. green
minn · 1967
2 sentences

1979The Act does not contain an irrebuttable presumption such as that invalidated in Twin City Candy & Tobacco Co., Inc. v. A. Weisman Co., 276 Minn. 225 , 149 N.W.2d 698 (1967). 4 In response to documented cases of consumer loss and confusion, the Act merely requires that certain disclosures be made to the customer to mitigate confusion and unreasonable expectations and provides economic protection against customer losses.

1979The Act does not contain an irrebuttable presumption such as that invalidated in Twin City Candy & Tobacco Co., Inc. v. A. Weisman Co., 276 Minn. 225 , 149 N.W.2d 698 (1967). 4 In response to documented cases of consumer loss and confusion, the Act merely requires that certain disclosures be made to the customer to mitigate confusion and unreasonable expectations and provides economic protection against customer losses.

21975–1979
Mitchell v. Steffen green
minnctapp · 1992
1 sentence

2013We noted that the statute “create[d] an irrebuttable presumption that all new residents come to Minnesota to collect higher benefits.” Id.

12013–2013
In Re the Welfare of L.J.S. green
minnctapp · 1995
2 sentences

2007And we further concluded that the presumptive-certification statute does not improperly create an irrebuttable presumption: “The juvenile may rebut the presumption ‘by demonstrating by clear and convincing evidence that retaining the proceeding in the juvenile court serves public safety.’ ” Id.

2007Specifically, “[t]he statute [ ] allows the juvenile to present evidence going beyond those basic facts to the broader issue of whether public safety is served.” Id.

12007–2007
County Court of Ulster Cty. v. Allen green
scotus · 1979
2 sentences

2004County Court of Ulster County v. Allen, 442 U.S. 140 , 157 n. 16, 99 S.Ct. 2213 , 2225 n. 16, 60 L.Ed.2d 777 (1979).

2004County Court of Ulster County v. Allen, 442 U.S. 140 , 157 n. 16, 99 S.Ct. 2213 , 2225 n. 16, 60 L.Ed.2d 777 (1979).

12004–2004
State, City of Mankato v. Chirpich green
minnctapp · 1986
1 sentence

1994In State v. Chirpich, 392 N.W.2d 34 (Minn.App.1986), pet. for rev. denied (Minn. Oct. 17, 1986), cert. denied, 481 U.S. 1015 , 107 S.Ct. 1891 , 95 L.Ed.2d 498 (1987), we stated that Minn.Stat. § 169.121, subd. 1(e) does not act as an irre-buttable presumption of guilt and impermis-sibly shift the burden of proof to the defendant.

11994–1994
National Elevator Industry, Inc. v. International Union of Elevator Constructors green
scotus · 1987
1 sentence

1994In State v. Chirpich, 392 N.W.2d 34 (Minn.App.1986), pet. for rev. denied (Minn. Oct. 17, 1986), cert. denied, 481 U.S. 1015 , 107 S.Ct. 1891 , 95 L.Ed.2d 498 (1987), we stated that Minn.Stat. § 169.121, subd. 1(e) does not act as an irre-buttable presumption of guilt and impermis-sibly shift the burden of proof to the defendant.

11994–1994
Adam v. Brotherhood Railway Carmen of the United States & Canada green
scotus · 1987
2 sentences

1994In State v. Chirpich, 392 N.W.2d 34 (Minn.App.1986), pet. for rev. denied (Minn. Oct. 17, 1986), cert. denied, 481 U.S. 1015 , 107 S.Ct. 1891 , 95 L.Ed.2d 498 (1987), we stated that Minn.Stat. § 169.121, subd. 1(e) does not act as an irre-buttable presumption of guilt and impermis-sibly shift the burden of proof to the defendant.

1994In State v. Chirpich, 392 N.W.2d 34 (Minn.App.1986), pet. for rev. denied (Minn. Oct. 17, 1986), cert. denied, 481 U.S. 1015 , 107 S.Ct. 1891 , 95 L.Ed.2d 498 (1987), we stated that Minn.Stat. § 169.121, subd. 1(e) does not act as an irre-buttable presumption of guilt and impermis-sibly shift the burden of proof to the defendant.

11994–1994
State v. Kelly green
minn · 1944
2 sentences

1992Respondent bases her argument on State v. Kelly, 218 Minn. 247 , 15 N.W.2d 554 (1944).

1992Respondent bases her argument on State v. Kelly, 218 Minn. 247 , 15 N.W.2d 554 (1944).

11992–1992
State v. Ferraro green
minn · 1980
1 sentence

1984This court has noted in the Ferraro decision that such qualifying instructions would prevent the jury from confusing a permissive inference with a mandatory presumption. 290 N.W.2d at 179 .

11984–1984
State v. Williams green
minn · 1982
2 sentences

1984Moreover, in the recent Minnesota case of State v. Williams, 324 N.W.2d 154 (Minn. 1982), a lack of qualifying instructions to the effect that the jury could consider the explanation or that it could disregard the presumption was important to the finding that the instruction given was “tantamount to an irrebuttable presumption that denies due process.” Id. at 160 citing Sandstrom v. Montana, 442 U.S. 510 , 99 S.Ct. 2450 , 61 L.Ed.2d 39 (1979).

1984Moreover, in the recent Minnesota case of State v. Williams, 324 N.W.2d 154 (Minn. 1982), a lack of qualifying instructions to the effect that the jury could consider the explanation or that it could disregard the presumption was important to the finding that the instruction given was “tantamount to an irrebuttable presumption that denies due process.” Id. at 160 citing Sandstrom v. Montana, 442 U.S. 510 , 99 S.Ct. 2450 , 61 L.Ed.2d 39 (1979).

11984–1984
Joseph E. Seagram & Sons, Inc. v. Hostetter green
scotus · 1966
2 sentences

1975Seagram & Sons, Inc. v. Hostetter, 384 U. S. 35 , 86 S. Ct. 1254 , 16 L. ed. 2d 336 (1966).

1975Seagram & Sons, Inc. v. Hostetter, 384 U. S. 35 , 86 S. Ct. 1254 , 16 L. ed. 2d 336 (1966).

11975–1975
Cleveland Board of Education v. LaFleur green
scotus · 1974
2 sentences

1975Any enforcement of the act by regulations which would employ an irrebuttable presumption is constitutionally offensive to due process as held by Cleveland Board of Education v. LaFleur, 414 U. S. 632 , 94 S. Ct. 791 , 39 L. ed. 2d 52 (1974); and Twin City Candy & Tobacco Co. Inc. v. A. Weisman Co. 276 Minn. 225 , 149 N. W. 2d 698 (1967), and will, we assume, be avoided. 21 Joseph E.

1975Any enforcement of the act by regulations which would employ an irrebuttable presumption is constitutionally offensive to due process as held by Cleveland Board of Education v. LaFleur, 414 U. S. 632 , 94 S. Ct. 791 , 39 L. ed. 2d 52 (1974); and Twin City Candy & Tobacco Co. Inc. v. A. Weisman Co. 276 Minn. 225 , 149 N. W. 2d 698 (1967), and will, we assume, be avoided. 21 Joseph E.

11975–1975
Kotter v. People green
ill · 1894
2 sentences

1903Kotter v. People, 150 Ill. 441 , 37 N. E. 932 .

1903Kotter v. People, 150 Ill. 441 , 37 N. E. 932 .

11903–1903

Where else courts name it

PA 152 (1900–2026) TX 115 (1968–2026) NC 76 (1907–2023) OH 75 (1974–2026) NY 59 (1924–2024) IL 42 (1894–2024) FL 36 (1947–2024) NJ 30 (1911–2026) CA 25 (1937–2025) TN 23 (1997–2018) MS 23 (1992–2020) MI 22 (1936–2026) LA 21 (1977–2024) IA 19 (1977–2023) AZ 18 (1906–2024) WA 17 (1932–2017) MD 17 (1946–2012) CT 16 (1981–2025) CO 16 (1887–2021) NM 15 (1974–2025) MN 14 (1903–2013) WI 14 (1978–2022) NE 13 (1977–2013) IN 12 (1980–2017) WY 11 (1977–2024) AL 10 (1990–2007) HI 10 (1972–2023) MO 9 (1978–2020) GA 9 (1981–2019) DE 9 (1959–2023) OK 8 (1935–2016) OR 8 (1914–2025) SC 7 (1963–2012) VA 6 (1983–2013) VT 5 (1978–2024) KS 5 (1995–2026) NH 5 (1986–2017) AK 5 (1979–1998) MA 5 (1975–2017) DC 5 (1978–2007) KY 4 (1994–1999) ID 4 (2022–2026) MT 4 (1975–2010) NV 4 (2018–2018) UT 3 (1983–1989) ND 2 (1984–1991) WV 2 (1949–1985) SD 2 (1943–1985) AR 2 (1985–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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